Place of removal determines CENVAT credit entitlement, hinging on when property in goods passes to the buyer or merchant exporter. Determination of place of removal for CENVAT credit follows the Sale of Goods Act: when a seller delivers goods to a carrier or bailee for transmission without reserving disposal, property passes to the buyer and that handover point (commonly factory gate, warehouse or depot) is the place of removal. For manufacturer-exporters the place of removal is the port/ICD/CFS where the shipping bill is filed; for merchant-exporter transactions it is where property passes from manufacturer to merchant exporter, usually the factory gate, but never beyond the port/ICD/CFS where the shipping bill is filed.